Australia announces expanded double tax treaty network

International Tax Review is part of Legal Benchmarking Limited, 4 Bouverie Street, London, EC4Y 8AX

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Australia announces expanded double tax treaty network

Sponsored by

Sponsored_Firms_piper.png
A significant expansion of Australia’s double tax treaty network has been announced

Jock McCormack of DLA Piper describes how the expansion of the double tax treaty network in Australia is very timely and well supported.

The Australian treasurer, Josh Frydenberg, announced on September 15 2021, a significant expansion of Australia’s double tax treaty network to stimulate economic integration through foreign investment and trade, among other things.

It is intended that Australia will enter into 10 new or updated double tax treaties by the end of 2023, the first phase of which will include a revised Indian–Australian treaty as well as new treaties with Luxembourg and Iceland.

Further revised or new treaties are proposed with Greece, Portugal and Slovenia.  According to the government’s media release, six of the 10 countries have been identified at this time with further analysis and consultation planned with a view to determining further treaty updates/renewals. 

In recent years, Australia has entered into two new treaties most importantly with Israel in 2020 and Germany in 2017.

The government has restated its commitment to modernise and expand Australia’s double tax treaty network and has committed critical resources and funding to support this expansion of Australia’s double tax treaty network.

Australia has 45 bilateral double tax treaties which will be significantly expanded by this recently announced initiative. The government has welcomed a public consultation along with a formal submission process with submissions due by October 31 2021.

Australia has been a strong supporter of the multilateral instrument which was largely operative for many of our existing double tax treaties from 2019–2020.

Although no decisions have been made at this stage various features associated with the OECD/G20 BEPS initiatives is expected including related to transparent entities, permanent establishments, concessional dividend, interest and royalty withholding taxes, limitation on treaty benefits, mutual agreement procedure, dispute resolution/arbitration and related initiatives. 

Australia was an early supporter of BEPS 1.0 including the related action plans, and has been actively involved in BEPS 2.0 including the proposed pillars one and two which are currently the subject of much global discussion and negotiation.

With the increasing integration and overlay of economic, foreign investment and security arrangements globally, this government initiative is very timely and well supported.



Jock McCormack

Partner, DLA Piper Australia

E: jock.mccormack@dlapiper.com 

 

more across site & shared bottom lb ros

More from across our site

Meanwhile, South Africa’s finance minister has accepted a court decision on suspending a VAT increase and US President Donald Trump mulls a 100% tariff on foreign films
Jaime Carey speaks about the benefits of his tax background, DEI values, the use of AI for a smarter legal practice, and other priorities that will define his presidency
Historically low levels of attrition over consecutive years made a ‘difficult decision’ necessary, PwC has reportedly said
WTS Global is also vetting new potential member firms in Algeria, Cote D’Ivoire and Benin, Kelly Mgbor tells ITR in an exclusive interview
The scope of qualifying pillar two tax credits could reportedly be broadened; in other news, hundreds of IRS appeals staff are to resign
For many taxpayers, the prospect of long-term certainty that a bilateral APA offers can override concerns about time, cost and confidentiality
Levine, who served under the Joe Biden administration, led the US’s negotiations on the OECD’s two-pillar solution
The deal to acquire ITR's parent company is expected to complete by the end of May 2025
JBS, the biggest meat company in the world, allegedly used Luxembourgian ‘mailbox companies’ to avoid taxes between 2019 and 2022
Despite the conviction of Jessa Dabalos, the Tax Practitioners’ Board’s investigative work continues with five outstanding PwC scandal probes
Gift this article